Privacy Policy

1. Tinco Industries

Respect for your privacy and protection of your personal data are matters we really care about.
We collect and process your personal data whenever you access our application ‘Pro-auction’ or our website online at www.eproauction.com or any alternative address (the “site”) and ask us to provide our services to you via any desired medium. This Charter of Personal Privacy (the “Charter”) explains the various ways we are allowed by law to use your personal data.
We suggest that you read this charter carefully before you submit your personal data to us. By accessing this website or using our services (or both) you indicate that you agree to let us collect and manage your personal data in certain ways, subject to the terms and conditions of use described below. If you do not agree with the charter, please exit this website and do not use it again.
This charter is an integral part of the terms and conditions of use of the website (“the terms and conditions of use”) and must be read together with them. This Privacy Policy statement is made by the Tinco Industries consisting of all the entities listed here (collectively, "Tinco", "we", "us" or "our").

2. Scope of this Privacy Policy

This Privacy Policy applies to the application Pro-Auction, the site or any other application which may be developed by us that link to it. It also applies to products and services provided by Tinco through these websites, our mobile applications, and applications posted by Tinco on Tinco’s online marketplace and in other third-party online marketplaces. This Privacy Policy does not apply to any of our websites, products or services that have a separate privacy policy.

This Privacy Policy is divided into three parts:

Part

Part I – Information Tinco collects and controls

Part II – Information that Tinco processes on your behalf

Part III – General

This part deals with topics that are relevant to both Parts I and II, and other general topics such as Tinco's security commitments and how we will inform you when we change this Privacy Policy.

Part I - Information Tinco collects and controls

a. What information Tinco collects

We collect information about you only if we need the information for some legitimate purpose. Tinco will have information about you only if (a) you have provided the information yourself, (b) Tinco has automatically collected the information, or (c) Tinco has obtained the information from a third party. Below we describe the various scenarios that fall under each of those three categories and the information collected in each one.

b. Information that you provide us

I Account signup : When you sign up for an account to access one or more of our services, we ask for information like your name, organisation details including but not limited your organisation GST number, contact number, email address, personal details, product requirements and country to complete the account signup process. You'll also be required to choose a unique username and a password for accessing the created account. You may also provide us with more information such as your photo, time zone and language. During logging in the account, we shall have access to specific message for purpose of auto-reading of the one-time password in cases applicable including but not limited to cases of resetting a forgotten password.

II Form submissions and chat box: We record information that you submit when you (i) submit a form in order to download any product or other materials, (ii) submit a form to enlist any product which contain product details including but not limited to technical specifications/product mix/commercial specifications, (iii) fill any form for submission of bids for product(s) which include sensitive price data, (iv) information exchanged vide the chat box available on app or site, (v) participate in contests or respond to surveys, (vi) submit bids containing sensitive information or (vii) submit a form to request customer support, get a quote or to contact Tinco for any other purpose.

III Testimonials : When you authorize us to post testimonials about our products and services on websites, we may include your name and other personal information in the testimonial. You will be given an opportunity to review and approve the testimonial before we post it. If you wish to update or delete your testimonial, you can contact us at smit@eproauction.com

IV Interactions with Tinco : We may record, analyze and use your interactions with us, including email, telephone, and chat conversations with our sales and customer support professionals, for improving our interactions with you and other customers.

c. Information that we collect automatically

I Information from browsers, devices and servers : When you visit our application and websites, we collect information that web browsers, mobile devices and servers make available, such as the internet protocol address, browser type, language preference, time zone, referring URL, date and time of access, operating system, mobile device manufacturer and mobile network information. We include these in our log files to understand more about visitors to our websites.

II Information from cookies and tracking technologies : We use temporary and permanent cookies to identify users of our services and to enhance user experience. We embed unique identifiers in our downloadable products to track usage of the products. We also use cookies, beacons, tags, scripts, and other similar technologies to identify visitors, track website navigation, gather demographic information about visitors and users, understand email campaign effectiveness and for targeted visitor and user engagement by tracking your activities on our websites. We use first-party cookies and third-party cookies. However, we do not use any other third-party tracking technologies on our websites or application for non-essential or intrusive tracking. You can learn more about the cookies used on our websites. We also use first-party Local Storage Objects (LSOs) such as HTML5 to store content information and preferences to provide certain features.

III Information from application logs and mobile analytics : We collect information about your use of our products, services and mobile applications from application logs and usage analytics tools, and use it to understand how your use and needs can improve our products. This information includes clicks, scrolls, features accessed, access time and frequency, errors generated, performance data, storage utilized, user settings and configurations, and devices used to access and their locations.

d. Information that we collect from third parties

I Referrals : If someone has referred any of our products or services to you through any of our referral programs, that person may have provided us your name, email address and other personal information. You may contact us at smit@eproauction.com to request that we remove your information from our database. If you provide us information about another person, or if another person gives us your information, we will only use that information for the specific reason for which it was provided to us.

II Information from our partners and service providers: The application and site use tools such as firebase messaging, Google analytics, and crashlytics for analysing and processing data. If you contact any of our partners enlisted, or otherwise express interest in any of our products or services to them, the partner may pass your name, email address, company name and other information to us. If you register for or attend an event that is sponsored by us, the event organizer may share your information with us. Tinco may also receive information about you from review sites if you comment on any review of our products and services, and from other thirdparty service providers that we engage for marketing our products and services.

III Information from social media sites and other publicly available sources : When you provide feedback or reviews about our products, interact, or engage with us on marketplaces, review sites or social media sites such as Facebook, Twitter, LinkedIn and Instagram through posts, comments, questions and other interactions, we may collect such publicly available information, including profile information, to allow us to connect with you, improve our products, better understand user reactions and issues, or to reproduce and publish your feedback on our websites. We must tell you that once collected, this information may remain with us even if you delete it from these sites. Tinco may also add and update information about you, from other publicly available sources.

e. Purposes for using information

In addition to the purposes mentioned above, we may use your information for the following purposes:

1. To communicate with you (such as through email) about products that you have downloaded and services that you have signed up for, changes to this Privacy Policy, changes to the Terms of Service, or important notices;
2. To keep you posted on new products and services, upcoming events, offers, promotions and other information that we think will be of interest to you;
3. To ask you to participate in surveys, or to solicit feedback on our products and services;
4. To set up and maintain your account, and to do all other things required for providing our services, such as enlisting product, saving product and pricing information, and backing up and restoring your data; •To understand how users use our products and services, to monitor and prevent problems, and to improve our products and services;
5. To provide customer support, and to analyze and improve our interactions with partners;
6. To detect and prevent fraudulent transactions and other illegal activities, to report spam, and to protect the rights and interests of Tinco, users, third parties and the public;
7. To update, expand and analyze our records, identify new customers, and provide products and services that may be of interest to you;
8. To analyze trends, administer our websites, and track navigations on our application and websites to understand what visitors are looking for and to better help them;
9. To monitor and improve marketing campaigns and make suggestions relevant to the user.

f. Legal bases for collecting and using information:

I Legal processing bases applicable to Tinco : If you are an individual from the European Economic Area (EEA), our legal basis for information collection and use depends on the personal information concerned and the context in which we collect it. Most of our information collection and processing activities are typically based on (i) contractual necessity, (ii) one or more legitimate interests of Tinco or a third party that are not overridden by your data protection interests, or (iii) your consent. Sometimes, we may be legally required to collect your information, or may need your personal information to protect your vital interests or those of another person.

II Withdrawal of consent : Where we rely on your consent as the legal basis, you have the right to withdraw your consent at any time, but this will not affect any processing that has already taken place.

III Legitimate interests notice : Where we rely on legitimate interests as the legal basis and those legitimate interests are not specified above, we will clearly explain to you what those legitimate interests are at the time that we collect your information.

g. Your choice in information use

I Opt out of non-essential electronic communications : You may opt out of receiving newsletters and other non-essential messages by using the ‘unsubscribe’ function included in all such messages. However, you will continue to receive essential notices and emails such as account notification emails (password change, renewal reminders, etc.), security incident alerts, security and privacy update notifications, and essential transactional and payment related emails.

II Disable cookies : You can disable browser cookies before visiting our websites. However, if you do so, you may not be able to use certain features of the websites properly.

III Optional information : You can choose not to provide optional profile information. You can always choose not to fill in non-mandatory fields when you submit any form linked to our application or websites.

h. Who we share your information with

Tinco Industries has access to the information covered in Part I. We do not sell any personal information. We share your information only in the ways that are described in this Privacy Policy, and only with parties who adopt appropriate confidentiality and security measures.

I Employees and independent contractors : Employees and independent contractors of relevant Tinco group entities have access to the information covered in Part I on a need-to-know basis. We require all employees and independent contractors of Tinco group entities to follow this Privacy Policy for personal information that we share with them.

II Third-party service providers : We may need to share your personal information and aggregated or de-identified information with partners enlisted on the application, third-party service providers that we engage including but not limited to firebase messaging, Google analytics, and crashlytics other third party contractors to operate and maintain the application, site; marketing and advertising partners, event organizers and other web analytics providers. These service providers are authorized to use your personal information only as necessary to provide these services to us.

III Partners: We shall share your personal information with our authorized partners solely for the purpose of contacting you about products that are enlisted. We will give you an option to opt out of continuing to work with that partner.

IV Other cases : Other scenarios in which we may share the same information covered under Parts I and II are described in Part III.

i. Your rights with respect to information we hold about you as a controller

If you are in the European Economic Area (EEA), you have the following rights with respect to information that Tinco holds about you. Tinco undertakes to provide you the same rights no matter where you choose to live.

I Right to access : You have the right to access (and obtain a copy of, if required) the categories of personal information that we hold about you, including the information's source, purpose and period of processing, and the persons to whom the information is shared

II Right to rectification : You have the right to update the information we hold about you or to rectify any inaccuracies. Based on the purpose for which we use your information, you can instruct us to add supplemental information about you in our database.

III Right to erasure : You have the right to request that we delete your personal information in certain circumstances, such as when it is no longer necessary for the purpose for which it was originally collected.

IV Right to restriction of processing : You may also have the right to request to restrict the use of your information in certain circumstances, such as when you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

V Right to data portability : You have the right to transfer your information to a third party in a structured, commonly used and machine-readable format, in circumstances where the information is processed with your consent or by automated means.

VI Right to object : You have the right to object to the use of your information in certain circumstances, such as the use of your personal information for direct marketing.

VII Right to complain : You have the right to complain to the appropriate supervisory authority if you have any grievance against the way we collect, use or share your information. This right may not be available to you if there is no supervisory authority dealing with data protection in your country.

j. Retention of information

We retain your personal information for as long as it is required for the purposes stated in this Privacy Policy. Sometimes, we may retain your information for longer periods as permitted or required by law, such as to maintain suppression lists, prevent abuse, if required in connection with a legal claim or proceeding, to enforce our agreements, for tax, accounting, or to comply with other legal obligations. When we no longer have a legitimate need to process your information, we will delete or anonymize your information from our active databases. We will also securely store the information and isolate it from further processing on backup discs until deletion is possible.

Part II – Information that Tinco processes on your behalf

a. Information entrusted to Tinco and purpose

I Information provided in connection with services : You may entrust information that you or your organization (“you”) control, to Tinco in connection with use of our services or for requesting technical support for our products. This includes information regarding your products, customers and your employees (if you are a controller) or data that you hold and use on behalf of another person for a specific purpose, such as a customer to whom you provide services. The data may either be stored on our servers when you use our services, or transferred or shared to us as part of a request for technical support or other services.

II Information from your devices : When you elect to allow it, our applications have access to the camera, microphone, call history, contact information, photo library, files and other information stored on your mobile device. Our applications require such access to provide their services. Similarly, when you elect to provide access, location-based information is also collected for purposes including, but not limited to, locating nearby contacts or setting location-based reminders. This information will be exclusively shared with our mapping providers and will be used only for mapping user locations. You may disable the applications' access to this information at any time by editing the settings on your device. The data stored on your mobile device and their location information to which the mobile applications have access will be used in the context of the application, and transferred to and associated with your account in the corresponding services (in which case the data will be stored on our servers) or products (in which case the data will remain with you unless you share it with us).

(All the information entrusted to Tinco is collectively termed “service data”)

b. Ownership and control of your service data

We recognize that you own your service data. We provide you complete control of your service data by providing you the ability to (i) access your service data, (ii) share your service data through supported third-party integrations, and (iii) request export or deletion of your service data.

c. How we use service data

We process your service data when you provide us instructions through the various modules of our services. For example, when you fill in technical details of a required product, information such as the name, specifications and pricing requirement, address will be used; and when you use our service for submission of response such details shall be shared with the vendors and shall be shared with the application to generate the automated response and comparison table.

d. Push notifications

If you have enabled notification on our desktop and mobile applications, we will push notifications through a push notification provider such as Apple Push Notification Service, Google Cloud Messaging or Windows Push Notification Services. You can manage your push notification preferences or deactivate these notifications by turning off notifications in the application or device settings.

e. Who we share service data with

I Tinco group and third party sub-processors : In order to provide services and technical support for our products, the contracting entity within the Tinco group engages other group entities and third parties .

II Employees and independent contractors : We may provide access to your service data to our employees and individuals who are independent contractors of the Tinco group entities involved in providing the services (collectively our “employees”) so that they can (i) identify, analyze and resolve errors, (ii) manually verify scanned images that you submit to us to verify the information. We ensure that access by our employees to your service data is restricted to specific individuals, and is logged and audited. Our employees will also have access to data that you knowingly share with us for technical support or to import data into our products or services. We communicate our privacy and security guidelines to our employees and strictly enforce privacy safeguards within the Tinco group.

III Third-party integrations you have enabled : Our products and services may support integrations with third-party products and services. If you choose to enable any third-party integrations, you shall be allowing the third party to access your service data and personal information about you. We encourage you to review the privacy practices of the third-party services and products before you enable integrations with them.

IV Other cases : Other scenarios in which we may share information that are common to information covered under Parts I and II are described in Part III.

f. Retention of information

We hold the data in your account as long as you choose to use our Services. Once you terminate your application user account, your data will eventually get deleted from active database during the next clean-up that occurs once in twelve (12) months. The data deleted from active database will be deleted from backups after three (3) months.

g. Data subject requests

If you are from the European Economic Area and you believe that we store, use or process your information on behalf of one of our customers, please contact the customer if you would like to access, rectify, erase, restrict or object to processing, or export your personal data. We will extend our support to our customer in responding to your request within a reasonable timeframe.

Part III – General

a. Children’s personal information

Our products and services are not directed to individuals under 16. Tinco does not knowingly collect personal information from children who are under 16 years of age for its own purposes. If we become aware that a child under 16 has provided us with personal information, we will take steps to delete such information. If you believe that a child under 16 years has provided personal information to us, please write to smit@tincoindia.com with the details, and we will take the necessary steps to delete the information we hold about that child. However, using our products, you can collect information about individuals who may be children. If you process information relating to children, you acknowledge and agree that you will be responsible for complying with the applicable laws and regulations related to protection of such personal information.

b. How secure is your information

At Tinco, we take data security very seriously. We have taken steps to implement appropriate administrative, technical & physical safeguards to prevent unauthorized access, use, modification, disclosure, or destruction of the information you entrust to us. If you have any concerns regarding the security of your data, we encourage you to write to us at smit@eproauction.com with any questions.

c. Locations and international transfers

We share your personal information and service data within the Tinco Group and with third parties engaged by Tinco Group for the purposes described above. By accessing or using our products and services or otherwise providing personal information or service data to us, you understand that the processing, transfer, and storage of your personal information or Service Data within the United States of America, the European Economic Area (EEA) and other countries. Such transfers are subject to appropriate data protection agreements such as a group company agreement that is based on EU Commission’s Model Contractual Clauses for data processing activities to which GDPR applies. You can write to smit@eproauction.com for obtaining a copy of the agreements on the basis of which we transfer your data within Tinco Group and with the third parties engaged by us.

d. Do Not Track (DNT) requests

Some internet browsers have enabled 'Do Not Track' (DNT) features, which send out a signal (called the DNT signal) to the websites that you visit indicating that you don't wish to be tracked. Currently, there is no standard that governs what websites can or should do when they receive these signals. For now, we do not take action in response to these signals.

e. External links on our websites

Some pages of our websites may contain links to websites that are not linked to this Privacy Policy. If you submit your personal information to any of these thirdparty sites, your personal information is governed by their privacy policies. As a safety measure, we recommend that you not share any personal information with these third parties unless you've checked their privacy policies and assured yourself of their privacy practices.

f. Social media widgets

Our application includes social media widgets such as Facebook "like" buttons and Twitter "tweet" buttons that let you share articles and other information. These widgets may collect information such as your IP address and the pages you navigate in the website, and may set a cookie to enable the widgets to function properly. Your interactions with these widgets are governed by the privacy policies of the companies providing them.

g. Disclosures in compliance with legal obligations

We may be required by law to preserve or disclose your personal information and service data to comply with any applicable law, regulation, legal process or governmental request, including to meet national security requirements.

h. Enforcement of our rights

We may disclose personal information and service data to a third party if we believe that such disclosure is necessary for preventing fraud, spam filtering, investigating any suspected illegal activity, enforcing our agreements or policies, or protecting the safety of our users.

i. Business Transfers

We do not intend to sell our business. However, in the unlikely event that we sell our business or get acquired or merged, we will ensure that the acquiring entity is legally bound to honor our commitments to you. We will notify you via email or through a prominent notice on our website of any change in ownership or in the uses of your personal information and service data. We will also notify you about any choices you may have regarding your personal information and service data.

j. Compliance with this Privacy Policy

We make every effort, including periodic reviews, to ensure that personal information you provide is used in conformity with this Privacy Policy. If you have any concerns about our adherence to this Privacy Policy or the manner in which your personal information is used, kindly write to us at smit@eproauction.com. We'll contact you, and if required, coordinate with the appropriate regulatory authorities to effectively address your concerns.

k. Notification of changes

We may modify the Privacy Policy at any time, upon notifying you through a service announcement or by sending an email to your primary email address. If we make significant changes to the Privacy Policy that affect your rights, you will be provided with at least thirty (30) days' advance notice of the changes by email to your primary email address. However, if you have not verified your email address, you may miss important notifications that we send through email. If you think that the updated Privacy Policy affects your rights with respect to your use of our products or services, you may terminate your use by sending us an email within 30 days. Your continued use after the effective date of changes to the Privacy Policy will be deemed to be your agreement to the modified Privacy Policy. You will not receive email notification of minor changes to the Privacy Policy. If you are concerned about how your personal information is used, you should check back at http://www.eproauction.com/ periodically.